November 2, 2007

Honorable JudyJeffrey
Director of Education
Iowa Department of Education
Grimes State Office Building
East 14th & Grand Streets
Des Moines, IA 50319-0146

Dear Director Jeffrey:

Thank you for your timely submission of Iowa’s corrective action plan in response to the Special Conditions document issued with the State’s 2007 Title III, Part A grant award.

The U.S. Department of Education (Department) understands, based on Iowa’s corrective action plan, that Iowa has not made accurate annual measurable achievement objective (AMAO) determinations for the 2003-04, 2004-05, and 2005-06 school years. While the State did make AMAO determinations, the State did not include AMAO 1 – student progress in attaining English language proficiency – in its AMAO calculations for any of these school years. The State’s corrective action plan explained that AMAO determinations could not be made accurately because of the State’s inability to track the achievement of individual Title III-served students over time. However, Iowa did not provide a corrective action for this finding.

As such, the Department finds Iowa’s current corrective action plan unacceptable. In order for the Department to accept Iowa’s corrective action plan, the State must add the following actions to its corrective action plan:

1)If the State is unable to make all three required AMAO determinations due to the lack of accurate data for past years, at a minimum, the Department expects Iowa to make AMAO determinations using AMAO 3 – adequate yearly progress (AYP) for the limited English proficient (LEP) subgroup -- for the 2003-04, 2004-05, and 2005-06 school years.

2)The State must notify its Title III local educational agencies (LEAs) and parents of current LEP/Title III students of the State’s failure to make accurate AMAO determinations for the 2003-04, 2004-05, and 2005-06 school years. The notifications must assure its LEAs and parents that all required AMAO determinations will be made for the 2006-07 school year and thereafter.

3) The State may decide to apply consequences retroactively to its LEAs based on revised AMAO determinations for the 2003-04, 2004-05, and 2005-06 school years. However, based on recent policy decisions, the Department is not requiring Iowa to take this action.

4) The State must submit, to the extent possible, missing or revised Consolidated State Performance Report (CSPR) data to the Department’s Education Data Exchange Network (EDEN) reflecting the revised AMAO determinations for previous school years, as well as any other identified data elements in the Special Conditions document. These data must be submitted to the Department by December 28, 2007. The Department recognizes that, based on the corrective actions, it may not be possible to submit some data elements for previous years.

5) The State must provide written assurance to the Department that all required AMAO determinations will be made for the 2006-07 school year and thereafter.

The Department requests that Iowa submit a revised corrective action plan to the Department that includes the corrective actions above within two weeks of receipt of this letter. The revised plan should be submitted to my attention, with a copy to Ms. Amy Weinmann, Education Program Specialist, OELA.

Thank you for your attention to these matters. We appreciate your efforts to implement a high-quality Title III program to address the needs of LEP students in your State.

Sincerely,

Margarita P. Pinkos, Ed.D.

Acting Assistant Deputy Secretary

cc: Carmen P. Sosa, Title III Director